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ATC Standards Should be Consistent & Transparent

"EPSA strongly supports the Commission's effort to establish methodologies for the consistent and transparent calculation of available transfer capability and available flowgate capacity to improve reliability in wholesale electricity markets" (NERC Filing)

WASHINGTON, D.C. - Yesterday, EPSA filed two sets of comments with the Federal Energy Regulatory Commission (FERC) supporting standards proposed by the North American Electric Reliability Corporation (NERC) and the North American Energy Standards Board (NAESB), but also asking for further clarity. Both sets of proposed standards focus on available transfer capability (ATC) consistent with Order 890, FERC's landmark open access transmission rule.

The NERC standards, which were proposed to alleviate reliability concerns, pose numerous implementation questions. While EPSA agrees that the Commission should require that all transmission service providers provide full access to standards implementation documents in order to achieve the transparency requirements of Order 890, EPSA still has concerns about the implementation process itself. "Further, there are concerns about the discretion that transmission providers are able to retain," EPSA's comments say.

The NAESB standards seek to institute common business practices and propose informational and posting requirements for ATC. EPSA's comments identify several important aspects where the proposed NAESB standards fall short of achieving FERC's Order 890 objectives. The areas EPSA identified are: a lack of transparency, a narrow interpretation of the scope of FERC Policy, and an overly broad transmission provider discretion.

EPSA President & CEO John E. Shelk said, "It is important to remember that resolving these technical issues is critical if this process is to be successful in addressing the transmission discrimination FERC has found remains a systemic problem outside of organized markets."

EPSA states that the Commission should consider the proposed NERC and NAESB standards concurrently. EPSA also recommends that FERC conduct open access transmission tariff audits along with NERC reliability audits. Additionally, EPSA asks for a technical conference to clarify the scope of the FERC and NERC audits as well as their related responsibilities and jurisdictional questions. In both sets of comments, EPSA strongly encourages FERC to limit the discretion of transmission providers, pushing for transparent, uniform standards implementation instead. "The Commission must strike a balance that accommodates actual implementation issues and not defer any longer the benefits of Order No. 890," EPSA says.

EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for nearly 40 percent of the installed generating capacity in the United States, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.